EFS-020
`
`ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BARNO.: 288097 FOR COURT USE ONLY
`NAME: Steve Papazian
`FIRM NAME: Papazian IP Law, APC
`STREET ADDRESS: 325 N. Larchmont Blvd., Ste 172
`cITy: Los Angeles STATE: CA ZIP CODE: 90004
`TELEPHONENO.: (562) 522-4086 FAXNO.: (213) 816-1931
`E-MAIL ADDRESS: steve@papazianiplaw.com
`ATTORNEY FOR (name): Plaintiff Cadence Design Systems, Inc.
`SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Clara
`STREET ADDRESS: 191 North First Street
`MAILING ADDRESS: 191 North First Street
`CITY AND ZIP CODE: San Jose, CA 85113
`BRANCH NAME: Downtown Superior Court CASE NUMBER:
`PLAINTIFF/PETITIONER: Cadence Design Systems, INc. 23CV417807
`DEFENDANT/RESPONDENT: TCL Industrial Holdings, Co., Ltd., et al JUDICIAL OFFICER:
`OTHER: Hon. Charles F. Adams
`DEPT:
`PROPOSED ORDER (COVER SHEET) 7
`NOTE: This cover sheet is to be used to electronically file and submit to the court a proposed order. The proposed order sent
`electronically to the court must be in PDF format and must be attached to this cover sheet. In addition, a version of the proposed
`order in an editable word-processing format must be sent to the court at the same time as this cover sheet and the attached proposed
`order in PDF format are filed.
`
`1. Name of the party submitting the proposed order:
`Plaintiff Cadence Design Systems, Inc.
`
`2. Title of the proposed order:
`[Proposed] Order Granting Stipulation re Case Deadlines
`
`3. The proceeding to which the proposed order relates is:
`
`a. Description of proceeding: Motion to Compel
`
`b. Date and time: August 7, 2025 at 1:30 PM
`
`c. Place: Santa Clara Superior Court, 191 North First Street, San Jose, CA 95113 (Dept. 7)
`
`4. The proposed order was served on the other parties in the case.
`
`Steve Papazian }
`(TYPE OR PRINT NAME) (SIGN@E@RTY OR ATTORNEY)
`Page 1 of 2
`Form Adopted for Mandatory Use PROPOSED ORDER (COVER SHEET) Cal. Rules of Court,
`Judicial Council of California
`
`. ags rules 2.252, 3.1312
`EFS-020 [Rev. February 1, 2017] (Electl"onlc Flllng) www.courts.ca.gov
`
`
`
`
`
`
`
`
`EFS-020
`
`CASE NAME: CASE NUMBER:
`Cadence Design Systems, Inc. v. TCL Industrial Holdings Co., Ltd., et al 23CVv417807
`
`PROOF OF ELECTRONIC SERVICE
`PROPOSED ORDER
`
`1. lam at least 18 years old and not a party to this action.
`
`a. My residence or business address is (specify):
`325 N Larchmont Blvd., Ste 172, Los Angeles, CA 90004
`
`b. My electronic service address is (specify): steve@papazianiplaw.com
`
`2. | electronically served the Proposed Order (Cover Sheet) with a proposed order in PDF format attached, and a proposed order in
`an editable word-processing format as follows:
`
`a. On (name of person served) (If the person served is an attorney, the party or parties represented should also be stated.):
`See attached proof of service
`
`b. To (electronic service address of person See attached proof of service
`
`c. Sserved): On (date): February 19, 2025
`
`Electronic service of the Proposed Order (Cover Sheet) with the attached proposed order in PDF format and service of the
`proposed order in an editable word-processing format on additional persons are described in an attachment.
`
`| declare under penalty of perjury under the laws of the State of California that the foregoing is true and
`correct. Date: 02/19/25
`
`Steve Papazian }
`(TYPE OR PRINT NAME OF DECLARANT) (SIGNATURE IOF DECLARANT)
`EFS-020 [Rev. February 1, 2017] PROPOSED ORDER (COVER SHEET) Page 2 of 2
`
`(Electronic Filing)
`
`
`
`
`
`
`
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`o
`
`~N O W
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`Filed
`
`February 25, 2025
`Clerk of the Court
`Superior Court of CA
`County of Santa Clara
`23CV417807
`
`By: MJacobo
`
`SUPERIOR COURT OF THE STATE OF CALIFORNIA
`
`FOR THE COUNTY OF SANTA CLARA
`
`CADENCE DESIGN SYSTEMS, INC., a
`Delaware Corporation,
`
`Plaintiff,
`V.
`
`TCL INDUSTRIAL HOLDINGS, CO., LTD.,
`a Chinese limited liability company, et al.,
`
`Defendants.
`
`Case No. 23CV417807
`
`HPROPOSED} ORDER GRANTING
`STIPULATION RE CASE DEADLINES
`
`[Stipulation filed concurrently herewith]
`
`Dept: Dept. 7 (Complex Civil Litigation)
`Judge: Hon. Charles F. Adams
`
`Complaint Filed: June 15, 2023
`Trial Date: None
`
`[PROPOSED] ORDER GRANTING STIPULATION
`
`
`
`
`
`
`
`
`
`10
`11
`12
`13
`14
`15
`16
`17
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`19
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`27
`28
`
`The Court, having considered the Parties’ Stipulation re Case Deadlines, hereby ORDERS
`
`as follows:
`
`The hearing on Cadence’s Motion to Compel (presently scheduled for August 7,
`2025) is advanced to March 20, 2025 at 1:30pm;
`
`Defendants shall produce supplemental discovery responses and produce documents
`in response to Cadence’s Form Interrogatories, Special Interrogatory Nos. 4 and 7,
`
`and RFPs 1-3, 5-8, 11-13, 16-22, 24-25, 35-36, and 40 no later than March 3, 2025;
`
`and
`
`Defendants shall file and serve their answers to Cadence’s First Amended Complaint
`
`no later than February 20, 2025
`
`IT IS SO ORDERED.
`
`Dated:
`
`2/24/2025 8:59:04 AM
`
`2
`
`(haudZEinmd-
`
`The Honorable Charles F. Adams
`California Superior Court Judge
`
`[PROPOSED] ORDER GRANTING STIPULATION
`
`
`
`
`
`
`
`
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`PROOF OF SERVICE
`
`I, the undersigned, declare that I am over the age of 18 years, employed in the County of Los
`Angeles, State of California, and not a party to the above-entitled action. On February 19, 2025, I
`
`caused to be served true and correct copies of the following documents to the listed recipients via
`
`email:
`
`e [PROPOSED] ORDER GRANTING STIPULATION RE CASE DEADLINES
`
`STEPTOE LLP
`
`Robyn C. Crowther (SBN 193840)
`rcrowther@steptoe.com
`
`Nicolena Farias- Eisner (SBN 336158)
`nfariaseisner@steptoe.com
`Geoffrey L. Warner (SBN 305647)
`gwarner(@steptoe.com
`
`633 West Fifth Street, Suite 1900
`Los Angeles, CA 90071
`Telephone: (213) 439-9400
`Facsimile: (213) 439-9599
`
`Attorneys for Defendants
`
`STEPTOE LLP
`
`J. William (“Bill”’) Toth (SBN 300055)
`btoth@steptoe.com
`
`Boyd Cloern (Pro Hac Vice Admitted)
`bcloern@steptoe.com
`
`1330 Connecticut Avenue, NW
`Washington, DC 20036
`
`Telephone: (202) 429-3000
`
`Facsimile: (202) 429-3902
`
`Attorneys for Defendants
`
`STEPTOE LLP
`
`gwang(@steptoe.com
`
`Beijing Representative Office,
`China Central Place,
`
`29th Floor, Tower 2,
`
`79 Jianguo Road,
`
`Chaoyang District
`
`Beijing, 100025.
`
`Yueyue “Grace” Wang (Pro Hac Vice forthcoming)
`
`Attorney for Defendants
`
`PROOF OF SERVICE
`
`
`
`
`
`
`
`
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`I declare under penalty of perjury under the laws of the State of California that the foregoing
`is true and correct.
`
`Executed on February 19, 2025 in Los Angeles, California.
`
`/s/ Steve Papazian
`
`Steve Papazian
`
`4
`
`PROOF OF SERVICE
`
`
`
`
`
`
`
`
`
`
`
`ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BARNO.: 288097 FOR COURT USE ONLY
`NAME: Steve Papazian
`FIRM NAME: Papazian IP Law, APC
`STREET ADDRESS: 325 N. Larchmont Blvd., Ste 172
`cITy: Los Angeles STATE: CA ZIP CODE: 90004
`TELEPHONENO.: (562) 522-4086 FAXNO.: (213) 816-1931
`E-MAIL ADDRESS: steve@papazianiplaw.com
`ATTORNEY FOR (name): Plaintiff Cadence Design Systems, Inc.
`SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Clara
`STREET ADDRESS: 191 North First Street
`MAILING ADDRESS: 191 North First Street
`CITY AND ZIP CODE: San Jose, CA 85113
`BRANCH NAME: Downtown Superior Court CASE NUMBER:
`PLAINTIFF/PETITIONER: Cadence Design Systems, INc. 23CV417807
`DEFENDANT/RESPONDENT: TCL Industrial Holdings, Co., Ltd., et al JUDICIAL OFFICER:
`OTHER: Hon. Charles F. Adams
`DEPT:
`PROPOSED ORDER (COVER SHEET) 7
`NOTE: This cover sheet is to be used to electronically file and submit to the court a proposed order. The proposed order sent
`electronically to the court must be in PDF format and must be attached to this cover sheet. In addition, a version of the proposed
`order in an editable word-processing format must be sent to the court at the same time as this cover sheet and the attached proposed
`order in PDF format are filed.
`
`1. Name of the party submitting the proposed order:
`Plaintiff Cadence Design Systems, Inc.
`
`2. Title of the proposed order:
`[Proposed] Order Granting Stipulation re Case Deadlines
`
`3. The proceeding to which the proposed order relates is:
`
`a. Description of proceeding: Motion to Compel
`
`b. Date and time: August 7, 2025 at 1:30 PM
`
`c. Place: Santa Clara Superior Court, 191 North First Street, San Jose, CA 95113 (Dept. 7)
`
`4. The proposed order was served on the other parties in the case.
`
`Steve Papazian }
`(TYPE OR PRINT NAME) (SIGN@E@RTY OR ATTORNEY)
`Page 1 of 2
`Form Adopted for Mandatory Use PROPOSED ORDER (COVER SHEET) Cal. Rules of Court,
`Judicial Council of California
`
`. ags rules 2.252, 3.1312
`EFS-020 [Rev. February 1, 2017] (Electl"onlc Flllng) www.courts.ca.gov
`
`
`
`
`
`
`
`
`EFS-020
`
`CASE NAME: CASE NUMBER:
`Cadence Design Systems, Inc. v. TCL Industrial Holdings Co., Ltd., et al 23CVv417807
`
`PROOF OF ELECTRONIC SERVICE
`PROPOSED ORDER
`
`1. lam at least 18 years old and not a party to this action.
`
`a. My residence or business address is (specify):
`325 N Larchmont Blvd., Ste 172, Los Angeles, CA 90004
`
`b. My electronic service address is (specify): steve@papazianiplaw.com
`
`2. | electronically served the Proposed Order (Cover Sheet) with a proposed order in PDF format attached, and a proposed order in
`an editable word-processing format as follows:
`
`a. On (name of person served) (If the person served is an attorney, the party or parties represented should also be stated.):
`See attached proof of service
`
`b. To (electronic service address of person See attached proof of service
`
`c. Sserved): On (date): February 19, 2025
`
`Electronic service of the Proposed Order (Cover Sheet) with the attached proposed order in PDF format and service of the
`proposed order in an editable word-processing format on additional persons are described in an attachment.
`
`| declare under penalty of perjury under the laws of the State of California that the foregoing is true and
`correct. Date: 02/19/25
`
`Steve Papazian }
`(TYPE OR PRINT NAME OF DECLARANT) (SIGNATURE IOF DECLARANT)
`EFS-020 [Rev. February 1, 2017] PROPOSED ORDER (COVER SHEET) Page 2 of 2
`
`(Electronic Filing)
`
`
`
`
`
`
`
`
`o
`
`~N O W
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`Filed
`
`February 25, 2025
`Clerk of the Court
`Superior Court of CA
`County of Santa Clara
`23CV417807
`
`By: MJacobo
`
`SUPERIOR COURT OF THE STATE OF CALIFORNIA
`
`FOR THE COUNTY OF SANTA CLARA
`
`CADENCE DESIGN SYSTEMS, INC., a
`Delaware Corporation,
`
`Plaintiff,
`V.
`
`TCL INDUSTRIAL HOLDINGS, CO., LTD.,
`a Chinese limited liability company, et al.,
`
`Defendants.
`
`Case No. 23CV417807
`
`HPROPOSED} ORDER GRANTING
`STIPULATION RE CASE DEADLINES
`
`[Stipulation filed concurrently herewith]
`
`Dept: Dept. 7 (Complex Civil Litigation)
`Judge: Hon. Charles F. Adams
`
`Complaint Filed: June 15, 2023
`Trial Date: None
`
`[PROPOSED] ORDER GRANTING STIPULATION
`
`
`
`
`
`
`
`
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`The Court, having considered the Parties’ Stipulation re Case Deadlines, hereby ORDERS
`
`as follows:
`
`The hearing on Cadence’s Motion to Compel (presently scheduled for August 7,
`2025) is advanced to March 20, 2025 at 1:30pm;
`
`Defendants shall produce supplemental discovery responses and produce documents
`in response to Cadence’s Form Interrogatories, Special Interrogatory Nos. 4 and 7,
`
`and RFPs 1-3, 5-8, 11-13, 16-22, 24-25, 35-36, and 40 no later than March 3, 2025;
`
`and
`
`Defendants shall file and serve their answers to Cadence’s First Amended Complaint
`
`no later than February 20, 2025
`
`IT IS SO ORDERED.
`
`Dated:
`
`2/24/2025 8:59:04 AM
`
`2
`
`(haudZEinmd-
`
`The Honorable Charles F. Adams
`California Superior Court Judge
`
`[PROPOSED] ORDER GRANTING STIPULATION
`
`
`
`
`
`
`
`
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`PROOF OF SERVICE
`
`I, the undersigned, declare that I am over the age of 18 years, employed in the County of Los
`Angeles, State of California, and not a party to the above-entitled action. On February 19, 2025, I
`
`caused to be served true and correct copies of the following documents to the listed recipients via
`
`email:
`
`e [PROPOSED] ORDER GRANTING STIPULATION RE CASE DEADLINES
`
`STEPTOE LLP
`
`Robyn C. Crowther (SBN 193840)
`rcrowther@steptoe.com
`
`Nicolena Farias- Eisner (SBN 336158)
`nfariaseisner@steptoe.com
`Geoffrey L. Warner (SBN 305647)
`gwarner(@steptoe.com
`
`633 West Fifth Street, Suite 1900
`Los Angeles, CA 90071
`Telephone: (213) 439-9400
`Facsimile: (213) 439-9599
`
`Attorneys for Defendants
`
`STEPTOE LLP
`
`J. William (“Bill”’) Toth (SBN 300055)
`btoth@steptoe.com
`
`Boyd Cloern (Pro Hac Vice Admitted)
`bcloern@steptoe.com
`
`1330 Connecticut Avenue, NW
`Washington, DC 20036
`
`Telephone: (202) 429-3000
`
`Facsimile: (202) 429-3902
`
`Attorneys for Defendants
`
`STEPTOE LLP
`
`gwang(@steptoe.com
`
`Beijing Representative Office,
`China Central Place,
`
`29th Floor, Tower 2,
`
`79 Jianguo Road,
`
`Chaoyang District
`
`Beijing, 100025.
`
`Yueyue “Grace” Wang (Pro Hac Vice forthcoming)
`
`Attorney for Defendants
`
`PROOF OF SERVICE
`
`
`
`
`
`
`
`
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`I declare under penalty of perjury under the laws of the State of California that the foregoing
`is true and correct.
`
`Executed on February 19, 2025 in Los Angeles, California.
`
`/s/ Steve Papazian
`
`Steve Papazian
`
`4
`
`PROOF OF SERVICE
`
`
`
`
`
`
`
`
`
`
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